BRCGS Packaging Materials Issue 7: What Food Businesses Need to Know Now

What’s New in BRCGS Packaging Materials Issue 7

A. Refined Hazard Analysis and Risk Assessment (HARA)

A core shift in Issue 7 is the alignment of HARA with Codex Alimentarius principles, bringing it closer to the structure of a traditional HACCP (Hazard Analysis and Critical Control Points) system.

⇒ Clearer subclauses for conducting hazard analysis

⇒ Greater emphasis on identifying both safety and quality risks

⇒ Expectation to assess not just biological, chemical, and physical risks but also operational risks like equipment failure or human error

Impact:

This means food packaging manufacturers must demonstrate a robust and structured risk management system, with up-to-date documentation and verification steps to ensure product integrity.

B. Stronger Requirements on Product Safety Culture

Issue 7 brings a substantial expansion of the clause on product safety culture.

⇒ Defining expected behaviors related to safety and quality

⇒ Regularly assessing employee performance against those expectations

⇒ Assigning accountability to all departments, not just the quality team

⇒ Mandatory implementation of a confidential reporting/whistleblowing mechanism

Impact:

Everyone—from line operators to engineers—must understand and articulate how their roles contribute to packaging safety. Training alone is no longer enough; companies must prove cultural buy-in and behavioral alignment during audits.

C. Allergen Risk Assessment and Management

Previously a general requirement, allergen control now demands a documented allergen management plan.

⇒ Mandatory allergen risk assessment for packaging materials

⇒ Implementation of control measures and employee training

⇒ Focus on indirect allergen risks (e.g., shared storage, cross-contamination in raw materials)

Impact:

Although allergens are rarely part of packaging materials themselves, contamination risks from inks, adhesives, or handling environments can affect final food safety outcomes.

D. Expanded Scope: Single-Use Consumer Products Included

Issue 7 explicitly includes single-use disposable items that blur the line between packaging and consumer products—like napkins, paper cups, takeaway containers, etc.

For manufacturers of such items:

⇒ Your products now fall under the BRCGS Packaging Standard

⇒ You must demonstrate conformity with safety, hygiene, and traceability requirements

Impact:

This reflects industry trends where food is increasingly served in the packaging itself—from fast food to ready meals—blurring the line between primary packaging and consumption tools.

E. Clarified Traceability Requirements

The updated standard demands more rigorous traceability system testing.

⇒ Requirement for traceability trials to be conducted at least annually

⇒ Tests must verify the ability to trace both forward and backward across the supply chain

⇒ Trials should include raw materials, processing steps, and end-product packaging

Impact:

This change boosts confidence in recall preparedness and demonstrates transparency to regulators and customers alike.

F. Outsourced Processes: Clarification and Control

For businesses that outsource parts of their production (e.g., printing, lamination, logistics):

⇒ You must identify all outsourced processes

⇒ Risk assessments must evaluate supplier reliability and process control

⇒ Controls should be clearly documented in supplier agreements

Impact:

This change emphasizes supply chain integrity. Businesses need to demonstrate that third-party activities meet the same safety and quality standards as their in-house operations.

G. Equipment and Infrastructure Compliance

Changes in line with GFSI benchmarks now apply to equipment used in packaging production.

⇒ Equipment design must prevent contamination (e.g., avoid dead ends or material traps)

⇒ Maintenance plans must be risk-based and documented

⇒ Engineering teams need to be trained to explain these changes during audits

H. Sustainability and Environmental Responsibility

While not mandatory for certification, sustainability is a strongly encouraged aspect of the new standard.

⇒ Identify the environmental impacts of packaging operations

⇒ Implement controls to manage waste, energy use, and recyclability

⇒ Consider design for recyclability and sustainable sourcing

This aligns with industry movements toward eco-conscious packaging and prepares businesses for future regulatory shifts.

I. Digital Transformation Encouraged

While not prescriptive, Issue 7 recognizes the role of digital tools in improving safety, traceability, and efficiency.

⇒ Digital document control systems

⇒ Automated traceability logs

⇒ Electronic Corrective and Preventive Action (CAPA) systems

⇒ Data dashboards for audit readiness

Digitization is becoming a competitive differentiator, especially for large brands and international supply chains.

BRCGS Packaging Materials Issue 7 is more than a routine update—it’s a strategic step towards more comprehensive packaging safety. For food businesses, now is the time to invest in system upgrades, employee training, and supplier oversight. With a focus on culture, accountability, and risk-based thinking, the new standard reinforces your brand’s reputation for safety and quality.